GuildHE is pleased to set out its vision for a more flexible and responsive higher education sector in our response to the Government’s HE reform and Lifelong Loan Entitlement consultations. Policy Manager Kate Wicklow summarises our response in our latest blog.

Lifelong Loan Entitlement

GuildHE has long championed the need for a more flexible, innovative and responsive higher education system. Key to this has been our call for a credit-based funding system. We believe this will benefit both institutions and students. It enables institutions to offer more innovative courses at different intensities of study and supports students who may wish to change courses, providers or change their study intensity more easily. We therefore strongly support the policy direction in ensuring that the Student Loan Company is equipped to manage accounts in this way. 

Higher education institutions have always been highly responsive to demand, whether from students or employers. We believe that the best way to encourage this is through policies that enable rather than limit this. In addition to an enabling  funding system it will be essential to have a strong and clear communications strategy for both prospective students as well as employers to help generate demand. It is also important to ensure that unintended barriers aren’t created through good intentions. Employer engagement in developing courses is important, and has been a feature of higher education provision for many years, but creating overly bureaucratic processes through IfATE may result in slowing down engagement. A key plank of any Government skills strategy should be employer funded training opportunities. These need to be encouraged and incentivised. It would be damaging to the skills needs of the country if the LLE became a way for employers to offset their training costs by passing them onto students. 

Similarly, regulation is essential to provide public reassurances but duplicating or even triplicating regulation through reporting to numerous different regulators will act as a brake on market development. This also links with the Government’s proposals around Level 4/5 reforms. Regulatory burden and overlap is a real concern. We know it is challenging merging two different adult education systems together but the solution cannot be to do regulation twice and there must be some compromises made by DfE, OfS, ESFA OFQUAL and IfATE. 

The Government’s target of 2025 is rightly ambitious to meet the country’s skills needs, but policy is best delivered when not rushed, but building on key priorities and based on piloting to get it right. 

Higher Education reform

The higher education sector has a proud track-record of widening participation to enable those that are able to benefit from higher learning and skills development to achieve this. Government proposed reforms around Student Number Controls, Minimum Eligibility Requirements and reducing funding for Foundation Years all have the potential to significantly impact and narrow educational opportunities.

Student number controls are highly complex to deliver centrally and would be a very blunt instrument, not suitable for fine-tuning higher education at the course or subject level. The OfS already has the power to restrict student numbers on the basis of a provider not meeting threshold quality standards, and it is right they use these powers where necessary. Anything more than this risks destabilising the sector and massively restricting student choice and equality of opportunities. 

When considering Minimum Eligibility Requirements it will be essential to undertake equality impact assessments, particularly for those students with disabilities and those with broken educational engagement. It would also be important to consider those with specific talents that have the capabilities to thrive in a HE environment without the prerequisite qualifications. We are also unsure as to the rationale in setting an adult learner as aged 25+ when the sector standard is 21. Finally, we recognise the importance of literacy and numeracy but feel that setting a MER linked to GCSE maths and English is a blunt tool and not in keeping with the prerequisite learning requirements of most HE programmes. 

Finally, on foundation years, we reject the premise that funding should be linked to Access to HE Diplomas as Year 0 courses are completely different. They have a greater intensity of learning, different levels of student support and are based directly in an HE environment. And they work. The OfS research found a significantly higher proportion of students progressing straight into a degree than from other access courses (70% for FYs versus 47% for Access to Higher Education courses). We are therefore worried that decreasing their unit cost of funding will decrease opportunities for those who need additional academic and pastoral support to thrive in a HE environment (especially after the impact of the pandemic on schools and youth mental health).

Finally, GuildHE fully supports any government intervention aiming to provide students with maintenance grant funding to support their studies. In general we think that any scholarship scheme should be based on an eligibility requirement built on financial disadvantage and not on prior attainment or choice of subject and call on DfE to put together a specific taskforce made up of WP, student finance academic and sector body leaders who understand the true financial barriers to attainment to design a truly impactful scheme. 


Read our full consultation response to HE reform

Read our full consultation response on LLE